2019 (3) TMI 86

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....f the case are that the M/s. Dharampal Satyapal Ltd. group is engaged in the manufacturing and trading of Chewing Tobacoo and premium pan masala besides other businesses. A search and seizure action u/s 132 of the Act was carried out on 21.01.2011 in the Dharampal Satyapal group of cases. The assessee, who is a Director in the group, had during the year earned income from salary, business and profession and other sources and the return of income was filed at an income of Rs. 56,99,270/-. The assessee's residence was also covered in the search as carried out on 21.01.2011. During the course of search at the assessee's residence, cash of Rs. 21,00,000/- was found and unexplained cash of Rs. 17,50,000/- was seized. In the return filed by the a....

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....ng the statement u/s 132(4) of the Act. In this regard, he drew our attention to the copy of statement recorded during the course of search. It was also submitted that the surrender of this amount was not made by the assessee during the course of search but was surrendered as income in the return of income filed. It was further submitted that the return filed by the assessee was accepted by the AO and no further additions were made. The Ld. Authorised representative placed reliance on the judgment of Hon'ble Delhi High Court in the case Pr. Commissioner of Income Tax vs. Emirates Technology Pvt. Ltd. reported (2017) 399 ITR 189 (Delhi) and submitted that the Hon'ble Delhi High Court had in this case upheld the order of the Tribunal holding ....